Privacy Policy

Purpose

 This Privacy Policy of Latrobe Health Services Limited and its related bodies corporate (‘Latrobe’, ‘we’, ‘us’, ‘our’) details our commitment to your privacy, our practices when handling personal information, your privacy rights, and the procedures and systems that are in place for the protection against inappropriate use of your personal information. Please read it carefully and if you have any questions, please contact us.

Please note that we also have an internal Employee and Contractor Privacy Policy which relates to the personal information of our past, current and prospective employees, contractors and other personnel.

Whose personal information do we collect?

Our commitment to privacy covers all persons whose personal information we hold. Therefore, any reference in this Privacy Policy to ‘you’ should be taken to mean and include a reference to the member named as the policy holder, any dependants of that member and any other persons whose personal information we hold.

What personal information do we collect?

Personal information is any information or an opinion about an individual whose identity is apparent or can reasonably be ascertained. Sensitive information refers to particular types of personal information including, but is not limited to, any information relating to an individual’s ethnicity or race, religion, or health.

We collect and hold a range of personal information, including:

• name;
• contact details, including addresses, phone numbers, email addresses and online profiles;
• family details, including spouse, partner and dependants information;
• demographic details, including age and gender;
• identity details, including date of birth, security credentials and government-issued identity numbers;
• information concerning your health and any medical services or hospital treatment, including details of where, when and from whom you have received that medical service or hospital treatment and the nature of it;
• bank account details;
• credit card details;
• details concerning your premiums and claims (if any) history, cover and change of cover, cancellations and suspensions of your policy with us and (where you transfer to us) your former health insurance funds;
• records of your interactions with us and responses to survey about your experience with us and health providers and other organisations we partner with;
• images and recordings, including CCTV at our sites and recordings of telephone calls we have with you;
• details relating to enquiries, claims, complaints and investigations;
• Medicare numbers of you and your dependants;
• if you pay your premiums through a payroll deduction scheme, information concerning your employer; and
• information concerning applications made and payments in respect of ambulance

Latrobe uses its own membership numbers to identify members. While in certain circumstances we need to collect your Medicare number to enable you to receive the Australian Government Rebate, we do not use this number to identify you.

See below section ‘Collection of information via the Latrobe Health Services digital platforms’ for more about information we collect.

Why do we collect personal information?

We may collect, hold, use and disclose your personal information for a range of functions and activities, including:

• providing our products and services as a health insurer;
• establishing and maintaining your membership, which includes processing applications and related administrative tasks such as changes to contact details or other information;
• verifying your identity and other information;
• processing health claims, and paying health benefits;
• managing, reviewing, improving our membership offerings, products and services or our business and operational processes and systems (including by obtaining feedback and undertaking analytics on claim data and other research activities and projects);
• updating the terms and conditions of your membership from time to time in accordance with changes to fund rules;
• providing you with information and offers about products and services offered by us and others which we believe may contribute to the overall health of you and your dependants, meet your other insurance requirements or otherwise be of interest to you (see below section ‘Marketing’);
• complying with our legal obligations, participating in legal and regulatory processes (including investigations and disputes), and exercising our legal rights, or as otherwise required by law;^[1]
• protecting the safety and security of our people, premises, systems and assets;
• administering ambulance cover;
• enabling you to collect the Australian Government Rebate by using your Medicare number;
• determining cover and eligibility for benefits by using information from your previous health insurer;
• determining waiting periods that may apply by referring to pre-existing ailment information;
• dealing with enquiries, claims, complaints and investigations

When we might disclose personal information

We may disclose your personal information in order to carry out our business functions and activities. The types of individuals and/or organisations to whom we disclose your personal information may include:

• the member named as the policy holder (or spouse) under a family cover policy concerning matters relating to the policy including levels of benefits available or paid under the policy;
• our contracted service providers who promote or assist us in administering or providing our products and services such as, for example, printers, mailing-houses, IT companies, internet service providers, credit card processing services and other relevant service providers;
• your employer, if you are part of a payroll deduction scheme or similar;
• your authorised representatives;
• other private health insurers to facilitate transfers between funds;
• hospitals and medical and other health service providers with whom you have had or may have a treatment episode and to whom fees may be payable;
• our strategic partners (such as the Australian Health Service Alliance) in relation to the provision of our products and services;
• our professional advisers, for example a dental adviser to review and validate claims, or an accountant or lawyer;
• parties involved in a corporate transaction such as a business sale, merger or acquisition, including purchasers, vendors and advisors;
• government agencies, courts and tribunals, where we are required or permitted by law; and
• other suppliers of products and services offered to you including ambulance

Latrobe does not generally disclose information to overseas recipients but on the rare occasion that we are required to do so, we will always ensure that you have consented to such disclosure, or that it is otherwise made in accordance with applicable law.

How do we collect personal information?

We may collect personal information about you from you directly, for example when you provide information to subscribe to or receive our services, interact with us, and through records of your activity. There are several ways we collect information from you including:

• When you open, start and complete an application form or other type of form in relation to your health insurance policy;
• When you contract us by phone, email, online, mail or in person;
• When you make a claim;
• When you visit our website, or mobile applications;
• When you participate in one of our community, health and wellness programs;
• When you participate in one of our research and marketing activities;

We may also collect personal information about you from other sources, including:

• family members, especially where a family member is the member named as the policy holder in a couple and family health insurance policy;
• our aggregators or corporate and strategic partners (such as the Australian Health Service Alliance) in relation to the provision of our products and services;
• hospitals and medical and other health service providers;
• your previous health fund, where you transfer to us;
• your employer, if you are part of a payroll deduction scheme or similar;
• government agencies;
• publicly available sources such as public registers, the internet and social media; and
• the third parties described under the section ‘When we might disclose personal information’ above.

Where you are a partner or dependant child covered by a couples or family health insurance policy, we may collect information about you from the policyholder who set up the policy. If you are 16 years or older, the policyholder must ensure that they have the authority and consent from you to provide your information to us.

We may also generate new information based on other information about you or attributed to you, for example through analysis, reviews, reporting and interpretation.

Collection of information via the Latrobe Health Services digital platforms

When you visit our digital platforms (our website, member portal and mobile application) information about the computer or web device you are using is automatically recorded. This includes your IP address, your domain name, the date and time of your visit to our site, the pages you accessed or downloaded, the last site you visited, your operating system, and the type of browser used.

This information is collected for statistical and administrative purposes, and to improve our web-based services. It does not readily identify individuals, and we will not attempt to identify individuals from the records generated unless it is necessary to do so for law enforcement purposes or by law or a court/tribunal order.

We may also use cookies to assign your device a user ID. Cookies contain information that allows us to identify your device. We may use this information to determine whether to display standard or personalised content. You can configure your browser so that it does not accept cookies, however this may minimise our ability to provide you with customised information.

We use third-party services to collect general information about how people use our digital platforms (Google Analytics and Hotjar). This anonymous information is aggregated and doesn’t reveal personally identifiable information about anyone who uses our website.

Further details can be found in the Terms of Use on the Latrobe Health Services website.

Marketing

Unless you contact us to opt out or we are otherwise limited by law, we may use your personal information to contact you (including by phone, text message or email) about products, services or information about your policy that we think may be of interest to you or necessary for you to be aware of. This may include our own, or a third party’s products or services.

In particular, we may contact you about products and services we think may be of interest to you after you cease to hold a private health insurance policy with us. For example, we might contact you about renewing your old policy or taking out a new policy.

How can I opt out of receiving marketing material?

You may opt-out of receiving marketing information from us at any time by:

• calling us on 1300 362 144;
• emailing us at info@lhs.com.au; or
• updating your marketing preferences on the online member services portal (latrobehealth.com.au).

Please allow five working days for your request to be actioned by us.

Security of personal information

Latrobe has implemented a range of steps to protect your personal information from interference, misuse, and loss, and from unauthorised modification, disclosure and access, in accordance with the requirements of the Australian Privacy Principles. We have in place a range of data security policies and procedures that aim to protect your information from both internal and external risks, including where the information is stored physically, electronically or with our service providers.

Dealing with us anonymously or with a pseudonym

You can deal with us anonymously or with a pseudonym (false name or alias). You may choose to do this for a number of reasons, for example, but not limited to, the following situations:

• if you are making a general inquiry about the benefits we pay on a procedure there would be no need to provide your personal details; and
• if you contact us to obtain a quote for health insurance, you are not obliged to provide us with personal details including your name or address however, the quote may not include any rebate or lifetime health cover calculations specific to your circumstances.

However, in some cases if you do not provide your personal information, we may not be able provide you with our products and services or comply with a request. For example, if you wish to verify that you are covered for a procedure and whether waiting periods or limits apply, membership details will be required. Further, if you are making a claim or applying to become a member, it is not lawful or practicable for you to deal with us anonymously or through a pseudonym.

Request for access to and correction of personal information

You may request access to the personal information we hold about you, or about any dependant aged less than 16 years or about any dependant of impaired capacity by writing to or contacting our Privacy Officer.

We will not charge a fee just because you make a request for access to your personal information. However, we reserve the right to charge a fee for the costs incurred in providing personal information in response to your request.

Depending upon the circumstances of your request for access, we may ask you to complete a personal information request form. The request must be supported by adequate personal identification to prove your entitlement to receive the requested information.

We will provide requested personal information in line with the Privacy Act. Where we are not obliged to provide the requested information, we may refuse your request. This includes, for example, where:

• providing access would pose a serious threat to the life, health or safety of any individual or to public health or public safety; or
• providing access would have an unreasonable impact upon the privacy of other individuals; or
• your request for access is frivolous or vexatious; or
• the information relates to existing or anticipated legal proceedings involving Latrobe and you, and would not be accessible by the process of discovery in these proceedings; or
• it is otherwise appropriate for us to refuse your request so that we can meet our obligations under law.

We will respond to your request within a reasonable period, usually 30 calendar days. If we refuse you access to any personal information, we will provide you with a reason for the refusal in writing. We may also consult with you to try to satisfy the request, including about the use of an agreed intermediary to receive the personal information rather than you if this is appropriate, or we may try to reach an amicable solution that meets the needs of all concerned, for example, giving access to the requested personal information in an alternative format.

If we become aware that information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading we will take reasonable steps to correct the information.

If you are aware that any of your personal information that we hold is incorrect, please let us know by contacting our Privacy Officer so that we can update our file. If any of your personal information is incorrect, we will take reasonable steps to correct that information, or if we refuse to do so, you will be provided with a reason for the refusal within a reasonable period, usually 30 days. In any event, if we do refuse to make a correction, we will, on request, record a statement from you claiming that the disputed information, in your opinion, is not correct.

You may request that we notify any third party to whom we have disclosed the incorrect information of the correction. We will then take reasonable steps to provide such notice, to the extent that it is practicable or lawful to do so.

Your right to complain

You can make a complaint at any time to us about any actual or perceived breach of our privacy obligations to you. Complaints should be directed to our Privacy Officer. Upon receipt of your complaint, our Privacy Officer will make contact with you (in writing and / or by telephone) to confirm receipt of your complaint and, if necessary, to advise you of any additional information we require to investigate your complaint.

Within a reasonable period, usually 30 days, of confirming receipt of your complaint (or receiving any further information required to investigate the complaint), we will respond in writing to you with the outcome of the investigation of your complaint including, if applicable, how we propose to resolve your complaint.

If you believe we have not resolved the issue you may refer the matter to the Australian Information Commissioner’s Office.

How can you contact us or the Office of the Australian Information Commissioner?

You can contact us at:

Address:

Latrobe Health Services

32 Darlimurla Avenue

NEWBOROUGH VIC 3825

Postal address:

PO Box 41

MORWELL VIC 3840

Telephone:         1300 362 144

Email:                   Privacy Officer: privacy@lhs.com.au

You can contact the Office of the Australian Information Commissioner at: Address:

GPO Box 5218

SYDNEY NSW 2001

Telephone:           1300 363 992

Facsimile:              (02) 6123 5145

Website:                www.oaic.gov.au

 

[1] We are required or authorised by various laws to collect personal information, including the Anti-Money Laundering and Counter-Terrorism Financing Act, Autonomous Sanctions Act, Australian Securities and Investments Commission Act, Corporations Act, Income Tax Assessment Acts and other tax laws, Privacy Act, Private Health Insurance Act, surveillance devices acts, Telecommunications (Interception and Access) Act.